Practical Results of Individual Tax Settlements: a Study on Agreements Entered by the National Treasury Attorney Office of the 2nd Region

Abstract

After a long period of gradual implementation at the federal level, tax settlement has emerged as a relevant alternative method for resolving tax disputes. Its practical effects became evident with the enactment of Law No. 13,988/2020 and PGFN Ordinance No. 6,757/2022. The impact was clear in the first years of effectiveness, with a high rate of taxpayer participation and increased revenue collection. This study aims to understand, through data, the elements and benefits granted to parties entering into such agreements, specifically in the context of individual tax settlements. It analyzes agreements signed between taxpayers and the Regional Office of the National Treasury Attorney in the 2nd Region, to identify metrics, patterns, and concepts used in negotiations between taxpayers and the tax authorities. The sample space allows the conclusion that there is room for genuine negotiations, enabling taxpayers who choose this modality to seek favorable agreements that facilitate their tax regularization by reducing the consequences of a substantial tax liability.